General Description of Advisory Firm Deerfield Financial Advisors, Inc. (also referred to as Deerfield Financial Advisors, Deerfield, and the Firm) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Corporation formed under the laws of the State of Indiana.
• The Firm’s President and Chief Operating Officer is Susie Steel.
• The Firm’s Vice President and Chief Investment Officer is Bradley Cougill.
• The Firm’s Chief Compliance Officer is Marsha Kalasmiki.
• Ms. Steel and Mr. Cougill are the controlling owners of the Firm.
• Deerfield Financial Advisors has been registered as an investment advisor since September 5, 1985.
• Through Deerfield Financial Advisors, we offer and consider ourselves to specialize in providing personalized fee-only Financial Planning and Investment Advisory Services. Description of Advisory Services Clients are advised that the investment recommendations and advice we offer does not constitute legal or accounting advice. Therefore, clients should coordinate and discuss the impact of financial advice with their attorney and/or accountant. Clients are advised that it is necessary to inform Deerfield Financial Advisors promptly with respect to any changes in their financial situation, investment goals and objectives. Failure to notify Deerfield Financial Advisors of any such changes could result in investment recommendations not meeting the needs of the client. Deerfield Financial Advisors is not required to verify information received from a client or from the client's other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on information provided by clients. Deerfield Financial Advisors may recommend other professionals to implement certain types of recommendations that we may not be able to implement ourselves or lack the necessary expertise. Clients are under no obligation to act upon any of the recommendations made by Deerfield Financial Advisors under a Financial Planning and Consulting engagement (including reports generated through our Wealth Management Services) and/or engage the services of any recommended professional. Wealth Management Services Deerfield Financial Advisors provides advisory services in the form of Wealth Management Services which can be described as a broad range of financial planning, investment management (see below), and financial planning and investment consulting (see below). Through this service, we essentially combine our Investment Management Services with consulting on other “non-managed” accounts while also developing financial planning and advice (see Financial Planning and Consulting Services below). Investment Management Services We provide advisory services in the form of Investment Management Services. Investment Management Services involve providing clients with continuous and on-going supervision over client accounts. This means that Deerfield Financial Advisors will continuously monitor a client’s account and make trades in client accounts when necessary. Through this service, Deerfield Financial Advisors implements a customized and individualized investment program for clients by applying our investment strategy and philosophy. Deerfield Financial Advisors shall actively manage client investment portfolios in accordance with the client's individual needs, return objectives and risk tolerance. Investment Management Services are primarily provided through accounts at Charles Schwab & Company, Inc. (“Charles Schwab”) as a result of the Firm’s participation in the Schwab Advisor Services platform. Charles Schwab is a registered broker/dealer, members of the Financial Industry Regulatory Authority (FINRA) and the Securities Investors Protection Corporation (SIPC) and will serve as the client’s qualified custodian and maintain physical custody of all client funds and securities. We are also willing to manage accounts held at other broker/dealers and qualified custodians selected by the client (conditional upon our approval) including variable annuities owned by the client and accounts established directly at retirement plan sponsors. Clients must designate Deerfield Financial Advisors as their investment advisor on the accounts they’d like us to manage. Deerfield Financial Advisors will be granted limited power-of-attorney on the account to implement trades within the account and (when agreed to by the client) deduct the Deerfield Financial Advisors advisory fees from the account. Please refer to Item 12 for more information regarding the Firm’s brokerage arrangements. Clients are always responsible for notifying Deerfield Financial Advisors of any changes to their financial situation or investment objectives. At least annually, we will contact each client for the specific purpose to determine whether the client’s financial situation or investment objectives have changed. We are always reasonably available to consult with clients relative to the status of their accounts. A client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the accounts. A separate account is always maintained for each client with the broker-dealer/custodian and the client retains all rights of ownership to their accounts (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important to understand that Deerfield Financial Advisors manages investments for other clients and can give them advice or take actions for them or for our personal accounts that is different from the advice we provide to a particular client or actions we take on their behalf. We are not obligated to buy, sell or recommend to a particular client any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for each client’s account(s) and other accounts advised by our Firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Clients can make additions to their accounts in cash or securities provided that Deerfield Financial Advisors reserves the right to liquidate any transferred securities or decline to accept particular securities into a client's account. Deerfield Financial Advisors will consult with clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Investment Management Services through Schwab Institutional Intelligent Portfolios Program For clients with small account sizes, we can recommend the use of and provide portfolio management services through Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, we offer clients with smaller account sizes a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client can instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab, an affiliated company of SWIA. The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. We have contracted with SWIA to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Clients do not pay fees to SWIA in connection with the Program, but we charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Charles Schwab as part of the Program. But Charles Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. We do not pay Charles Schwab fees for its services in the Program so long as we maintain $100 million in client assets in accounts at Charles Schwab that are not enrolled in the Program. If we do not meet this condition, then we pay SWIA an annual fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with Charles Schwab. Please see additional information regarding our arrangement with Charles Schwab at Item 12 of this brochure. Financial Planning and Consulting Services Financial Planning We provide advisory services in the form of financial planning consultations and written financial planning. Financial Planning Services do not involve the active management of client accounts, but instead focus on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through business planning, investment management, tax and cash-flow planning, asset allocation, risk management, retirement planning, estate planning, education planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Financial planning discussions begin at the onset of the relationship and are integrated into investment planning while investments are transferred, or changes are initiated to portfolios that have been transferred to Deerfield Financial Advisors for its Investment Management Services (see following section). Financial Planning Services can be specific or modular in their preparation (unique to each client in their depth of preparation). Specific issues covered in a financial plan are contingent upon each client’s unique needs and circumstances, but the following are basic areas in which our planning may focus.
• Business Planning
• Investment Management
• Insurance/Risk Management (Life, Disability, and Long-Term Care)
• Retirement Planning
• Education Planning
• Estate Planning
• Tax Planning and Cash Flow Needs Analysis Financial Planning Services take into consideration factors such as a client’s financial/investment objectives, risks they are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions, stock options, social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for retirement. While Financial Planning Services are prepared with the intention of clients implementing recommendations made within the plan through our Investment Management Services, they are not obligated to do so. If clients elect to implement our advice provided as part of the Financial Planning Services, implementation will be made through the Investment Management Services described below. Investment Consulting We also provide advisory services in the form of oral and written investment consulting services. Similar to our Investment Management Services, we review and analyze investment holdings in light of the specific type of account, but we will not be involved

with implementing any recommendations. Clients receiving this service must understand that the Firm may or may not provide on-going reviews of accounts through this service and information about such accounts is limited to information provided exclusively by the client. Clients always have the sole discretion to accept or reject the Firm’s advice. The client must implement all trades in such accounts because the Firm will not have discretion over such account. Investment consulting services may cover, but are not limited to, the following topics: portfolio analysis, asset allocation strategies, and specific investment recommendations. The Firm provides consulting services on accounts and other investment holdings owned by the client but not included under the Firm’s Investment Management Services. These are accounts for which trading authorization is not granted to the Firm. Examples include a client’s 401(k) or other retirement account, 529 college planning account, and other accounts held “away” from the Firm’s platform. Clients must understand that the Firm does not provide on-going reviews of such accounts, and information about such accounts is limited to information provided exclusively by the client. When Deerfield Financial Advisors provides consulting advice on accounts and investments, the client will have the sole discretion to accept or reject the Firm’s advice. The client must implement all trades in such accounts because the Firm will not have discretion over such account. Clients are free to implement any or all of the recommendations made by Deerfield Financial Advisors with another financial institution and are not obligated in any manner to implement the advice of Deerfield Financial Advisors through the Firm. See Item 5 of this Brochure for fee descriptions. Investment Monitoring We also provide advisory services in the form of oral and written investment monitoring services. These investment monitoring services are limited aspects of our Investment Management Services. Clients receiving this service must understand that the Firm may or may not provide on-going reviews of accounts through this service and information about such accounts is limited to information provided exclusively by the client. Clients always have the sole discretion to accept or reject the Firm’s advice. The client must implement all trades in such accounts because the Firm will not have discretion over the account(s). Deerfield Financial Advisors provides investment monitoring services in the form of oral commentary and written reporting. Investment monitoring services cover the following topics: account reconciliation, performance calculation, portfolio reporting, asset allocation statement, cost basis tracking, and year-end tax reporting. The Firm may provide investment monitoring on accounts and other investment holdings owned by the client but not included under the Firm’s investment management services. These are accounts for which trading authorization is not granted to the Firm. Examples include a client’s 401(k) or other retirement account or other accounts held “away” from the Firm’s platform. Clients must understand that the Firm does not provide on-going reviews of such accounts, and information about such accounts is limited to information provided by the client, the custodian, and/or electronic data feeds for account transactions. When Deerfield Financial Advisors provides consulting advice on accounts and investments, the client will have the sole discretion to accept or reject the Firm’s advice. The client must implement all trades in such accounts because the Firm will not have discretion over such accounts. Clients are free to implement any or all of the recommendations made by Deerfield Financial Advisors with another financial institution and are not obligated in any manner to implement the advice of Deerfield Financial Advisors through the Firm. Retirement Plan Services Deerfield Financial Advisors offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services Deerfield Financial Advisors provides the following Fiduciary Retirement Plan Consulting Services in the form of Non-Discretionary Investment Advice. Through this service, Deerfield Financial Advisors will provide clients with general, non-discretionary investment advice regarding asset classes and investment options, consistent with their Plan’s investment policy statement (if available). We will not have investment discretion or any authority to add or remove investment options or trade securities of the Plan. All recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investment recommendations of Deerfield Financial Advisors and then physically make changes to the plan itself. Deerfield Financial Advisors acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Deerfield Financial Advisors will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Deerfield Financial Advisors to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Deerfield Financial Advisors (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Fiduciary Management Services Deerfield Financial Advisors provides clients with the Fiduciary Retirement Plan Management Services through our Discretionary Management Services. Through this service, we will provide clients with continuous and ongoing supervision over the designated retirement plan assets consistent with the plan’s investment policy statement (if available). We will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets at our sole discretion without first consulting with the client. We will also have the power and authority to carry out these decisions by giving instructions, on behalf of the client, to brokers and dealers and the qualified custodian(s) of the Plan. If a client elects to utilize our Fiduciary Management Services, then Deerfield Financial Advisors will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and Deerfield Financial Advisors hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Non-Fiduciary Consulting Services Deerfield Financial Advisors provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. Deerfield Financial Advisors will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Deerfield Financial Advisors’ assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. Deerfield Financial Advisors will assist clients with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. Deerfield Financial Advisors does not serve as administrator or trustee of the plan. Deerfield Financial Advisors will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to clients any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b- 2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Limits Advice to Certain Types of Investments We only provide investment advice on the following types of investments.
• Exchange-listed securities (i.e., stocks)
• Securities traded over-the-counter (i.e., stocks)
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares (primarily no-load mutual funds and funds traded at Net-Asset Value)
• Exchange Traded Funds (ETFs)
• United States government securities
• Options contracts on securities
• Interests in partnerships investing in real estate, oil and gas interests Deerfield Financial Advisors is available to provide advice on and consult with clients on private placement securities (which include, but are not limited to, debt, equity, real estate, and/or pooled investment vehicles) when consistent with the client’s investment objectives and appropriate for the client based on his or her unique financial situation. If a client decides to invest in a private placement security, the client will need to complete a subscription agreement showing he or she is an “accredited” investor (as defined by applicable law, rules and regulations) and acknowledge he or she has read and understands the private placement memorandum and is aware of the various risk factors of such an investment. When Deerfield Financial Advisors recommends that a client invests in private placement securities, it is important to know that Deerfield Financial Advisors does not receive compensation in the form of commissions, finder’s fees or other economic payments from the sponsors of private placement offerings. Moreover, we do not include the value of a client’s investment(s) in private placement securities when calculating our percentage-based assets under management fee. Instead, our time and analysis of private placement securities is covered by the fixed fee component of our wealth management services. When managing accounts through our Investment Management Services program we primarily allocate client assets among mutual funds, ETFs and/or individual debt securities in accordance with the investment objectives of the client. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each client. This means, for example, that we discuss the individual issues involved in transitioning current holdings into Deerfield’s Investment Management Services program and determine if we need to accommodate any nuances to make this happen in a tax efficient manner. Deerfield Financial Advisors works with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. When managing client accounts through the Firm’s Investment Management Services program, we manage accounts in accordance with multiple investment models that are developed and monitored by our investment team. Through the management of the models, each client’s portfolio is managed based on the underlying model to which it is assigned. The determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Client Assets Managed by Deerfield Financial Advisors The amount of client’s assets managed by Deerfield Financial Advisors totaled $831,472,258 as of December 31, 2023. $699,252,594 is managed on a discretionary basis and $132,219,664 is managed on a non-discretionary basis.